Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Statutory appellate authorities may condone delay in GST appeals only within the enactment's prescribed outer limit; equitable considerations or High Court directions issued under extraordinary jurisdiction cannot enlarge that power. Where the Department implemented an appellate order by restoring cancelled GST registrations, its subsequent challenge became infructuous because reversal could disrupt intervening transactions and input tax credit without workable consequential relief. Taxpayers retain an independent right to appeal registration cancellation when the common portal prevents a delayed revocation application; failure to seek revocation under Rule 23 does not extinguish that appellate remedy.
Statutory appellate authorities may condone delay in GST appeals only within the enactment's prescribed outer limit; equitable considerations or High Court directions issued under extraordinary jurisdiction cannot enlarge that power. Where the Department implemented an appellate order by restoring cancelled GST registrations, its subsequent challenge became infructuous because reversal could disrupt intervening transactions and input tax credit without workable consequential relief. Taxpayers retain an independent right to appeal registration cancellation when the common portal prevents a delayed revocation application; failure to seek revocation under Rule 23 does not extinguish that appellate remedy.
Note: It is a system-generated summary and is for quick reference only.
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